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Per-Battery vs Per-Model Passport: Why Article 77(1) Requires One Passport per Battery

Article 77(1) requires one battery passport per individual battery placed on the market — a single shared passport for a whole model or batch does not satisfy the regulation.

Last updated 1 June 2026

A common and costly mistake is to create one passport per battery model or per production batch and reuse it for every physical unit. Article 77(1) of Regulation (EU) 2023/1542 requires a battery passport for each individual battery that is placed on the market or put into service. The passport is tied to a specific physical battery through a unique identifier, not to an abstract product model.

Per-model or per-batch passports are non-compliant under Article 77(1). The regulation requires one passport per individual battery, each with its own unique identifier and life-cycle record.

Why one-per-battery is unavoidable

Much of the data the passport must carry is unit-specific and changes over the life of a single battery: its state of health, its current owner or status, repurposing or recycling events. A shared model-level record cannot represent these item-level facts, which is why the regulation fixes granularity at the individual battery.

Data layerSame across model?Belongs to
Chemistry, nominal capacity, manufacturerYesModel-static data
Unique identifier, date placed on marketNoItem-static data
State of health, status, lifecycle eventsNoItem-dynamic data

A correct design lets model-level data be authored once and inherited, while still issuing a distinct passport — with its own ISO/IEC 15459 identifier and URL — for every physical battery. Repurposing forks a new linked passport; recycling ends the passport. None of this is expressible with a single shared record.

  • One unique identifier per physical battery (ISO/IEC 15459).
  • One immutable passport URL per battery, kept reachable for the retention period.
  • Item-dynamic data updated over the life of that specific battery.
  • Model-static data authored once and reused, not flattened into a single passport.

Frequently asked

Can I use one battery passport for a whole model or batch?

No. Article 77(1) of Regulation (EU) 2023/1542 requires a battery passport for each individual battery. A passport shared across a model or batch is non-compliant.

Does authoring data per model mean I need separate data entry per battery?

No. Model-static data such as chemistry and nominal capacity can be authored once and inherited by every unit. Each physical battery still gets its own passport, unique identifier and item-level life-cycle record.

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